Draft ADA Action Plan - Home - Minneapolis Park ...€¦ · The updated accessibility standards and 25th anniversary of the ADA in 2015 have also presented MPRB with an opportunity

Minneapolis Park and Recreation Board

Draft ADA Action Plan 2018-2010

Minneapolis Park and Recreation Board Draft ADA Action Plan

Table of Contents

SUMMARY..................................................................................................................................................... 2

INTRODUCTION............................................................................................................................................. 2

PURPOSE ....................................................................................................................................................... 3

CURRENT STATUS OF ADA COMPLIANCE AND TRANSITION PLANNING ...................................................... 3

DEVELOPMENT OF AN ADA ACTION PLAN ................................................................................................... 4

ADA TITLE II ADMINISTRATIVE REQUIREMENTS........................................................................................... 4

Notice1. ................................................................................................................................................ 4

Designation of Responsible Employee 4

Complaint Procedure 6

Self-Evaluation: Policies, Practices and Procedures 7

Transition Plan: Existing Facilities 7

2. ..............................................................................................

3. ........................................................................................................................

4.

5.

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MODIFICATION OF POLICIES, PRACTICES & PROCEDURES .........................................................................10

ORGANIZATIONAL AND DEPARTMENTALPOLICY MODIFCATIONS 11

COMMUNICATIONS AND ADVANCE REQUESTS FOR AUXILARY AIDS, SERVICES AND ALTERNATE FORMATS ................................................................................................................................................14

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INCLUSIVE RECREATION SERVICES 15

EMPLOYMENT & PROFESSIONAL DEVELOPMENT 16

COMMUNITY ENGAGEMENT & INPUT FROM PEOPLE WITH DISABILITIES 18

RESOURCES 20

Appendix A MPRB ADA Public Notice 21

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Minneapolis Park and Recreation Board ADA Action Plan - 1

Minneapolis Park and Recreation Board ADA Action Plan

SUMMARY The Minneapolis Park and Recreation Board (MPRB) is updating their original 1992 Americans with

Disabilities Act (ADA) Transition Plan to incorporate the updates to federal guidelines that address

recreation facilities as well as emerging practices and technology. The 2018-2020 ADA Action Plan is a

working document that will guide MPRB ADA Transition planning priorities along with policy and

procedure revisions. A matrix of action-oriented tasks, lead assignments and timelines is embedded

throughout the document. While this is a short-term plan, this component establishes timelines and

accountability for each recommended task and establishes a framework for ADA compliance for the next

25 years.

This ADA Action Plan was developed through a multi-year process in conjunction with Recreation

Accessibility Consultants LLC., and Skulski Consulting LLC., with input from key community stakeholders

identified with the help of the Minneapolis Advisory Committee on People with Disabilities (MACOPD).

Key community stakeholders were invited to learn more about MPR�’s ADA Transition Plan, were asked

about other groups and individuals to engage, provided input on the questions MPRB planned to ask

during the engagement process and were invited to partner with the MPRB to cohost engagement

events with the communities they serve.

MPRB intends that this will be a living document that will be utilized regularly by all departments for

everything from capital planning to rehabilitation projects to recreation programming to

communications. This document is a stand-alone report, and the material contained in it will be

disseminated in various formats throughout the organization to ensure its recommendations are

followed and accessibility work is coordinated across the organization.

INTRODUCTION The Minneapolis Park and Recreation Board (MPRB) exists to provide places and recreation

opportunities for all people to gather, celebrate, contemplate, and engage in activities that promote

health, well-being, community, and the environment. We are committed to ensuring that MPRB

programs, policies, services and facilities are accessible to everyone who lives, works and plays in the

city of Minneapolis. This commitment is further defined in the Park �oard’s mission, vision, and values,

along with the specific goals outlined in our Comprehensive Plan 2007-2020.

Service to people with disabilities and compliance with the Americans with Disabilities Act (ADA)

continues to be a top priority. The MPRB last completed an ADA Transition Plan in 1992 as required

under Title II. This plan was a comprehensive inventory and analysis of MPRB facilities along with a

schedule for barrier removal to provide better access for people with disabilities. Substantial


https://www.minneapolisparks.org/about_us/mission_vision__values/

https://www.minneapolisparks.org/_asset/9h52lq/comprehensive_plan.pdf

accessibility improvements were made to facilities. In addition, an internal evaluation of policies,

practices and procedures was conducted shortly after the ADA was passed. Actions were taken to make

reasonable modifications to policies to ensure participation by people with disabilities.

PURPOSE In 2010, after the implementation of MPR�’s original 1992 ADA Transition Plan, the federal guidelines

were revised and updated to address access to recreation facilities as well as emerging practices and

technology. The revised standards and new guidance on recreation facilities highlighted the need for

MPRB to revisit its original ADA Transition Plan and make updates that are consistent with the 2010 ADA

Standards.

The updated accessibility standards and 25th anniversary of the ADA in 2015 have also presented MPRB

with an opportunity to revisit the agency ADA transition planning priorities along with policies and

procedures; The purpose of MPR�’s ADA Action Plan is to present a framework for ADA compliance for

the next 25 years.

CURRENT STATUS OF ADA COMPLIANCE AND TRANSITION PLANNING !s accessibility is everyone’s responsibility, MPR� is taking an organization-wide approach to improve

the accessibility of programs, policies, services and facilities. Several steps have been taken over the last

five years to facilitate long-term planning that is consistent with the 2010 ADA Standards for Accessible

Design specific to recreation facilities and the need to achieve “program access.” In 2010, a consultant

was contracted to provide accommodations within recreation services and to complete an inventory of

the MPRB park system.

In 2014, an ADA Transition Plan Work Group was assigned the task of preparing a request for proposals

to provide a complete and updated ADA inventory, assessment and transition plan. As a result, a

comprehensive accessibility assessment of parks and facilities was conducted under contract over the

course of the next year. In addition, the assessment included a review of policies, practices and

procedures for compliance with the ADA. During this period, MPR�’s Community Outreach Department

began managing the organization’s ADA Title II compliance responsibilities. The operational role of the

ADA Title II Coordinator position was assigned to one of the department’s �ommunity Outreach and

Access Coordinators. Within the year, the consultant provided findings and recommendations for

barrier removal of more than 19,000 elements to be brought into compliance with the 2010 ADA

Standards. The consultant also provided recommendations for policy modifications.

In 2015, MPRB partnered with the City of Minneapolis Civil Rights Department and Neighborhood and

Community Relations to organize a celebration of the 25th Anniversary of the ADA. The anniversary

provided an introspective opportunity for staff to process key findings and recommendations for

improving physical access to parks and facilities, while also making reasonable modifications to policies,

practices and procedures. In 2016, moving forward with one of the priority recommendations from the

consultant, a Certified Therapeutic Recreation Specialist was hired to serve as the agency’s inclusion

coordinator. The inclusion coordinator works directly with program participants with disabilities and

recreation staff to provide the most appropriate supports, modifications, auxiliary aids and services to

ensure that participants with disabilities can fully participate in and benefit from the programs, services

and activities offered by the MPRB.


DEVELOPMENT OF AN ADA ACTION PLAN This ADA Action Plan was drafted based on findings from the policy review and in an effort to further

outline purposeful strategies to achieve ADA compliance. The MPR�’s !D! !ction Plan outlines steps to

meet the current ADA Title II regulations set by the U.S. Department of Justice. The plan identifies

current standards as well as best practices above and beyond compliance regulations to support the full

inclusion of people with disabilities and to ensure that Minneapolis’s award-winning park system is

inclusive of and accessible to people with disabilities. A matrix of action-oriented tasks, lead

assignments and timelines is embedded throughout the document. The matrix will be periodically

updated by the ADA Coordinator. The public, especially people with disabilities and disability advocates,

are welcome and encouraged to provide comment on the ADA Action Plan at any time. Comments can

be submitted to Elise Niedermeier, ADA Coordinator, Minneapolis Park and Recreation Board, 2117

West River Road, Minneapolis, MN 55411, [email protected].

ADA TITLE II ADMINISTRATIVE REQUIREMENTS This section outlines the MPRB processes that have been put into place to meet the Title II

administrative requirements and ensure full inclusion of people with disabilities in MPRB programs,

services and activities. These requirements include making notice to the public; completing a review of

policies, practices and procedures in the form of a self-evaluation; outlining a grievance procedure for

ADA-related complaints; designating a responsible employee for agency compliance; and developing a

transition plan for the removal of physical and communication barriers to programs, services and

activities in existing facilities.

1. Notice Title II of the ADA requires that “a public entity shall make available to applicants, participants,

beneficiaries, and other interested persons information regarding the provisions of this part and its

applicability to the services, programs, or activities of the public entity, and make such information

available to them in such manner as the head of the entity finds necessary to apprise such persons of

the protections against discrimination assured them by the Act and this part;”1 MPRB personnel will

take the appropriate actions to ensure the agency’s intent to comply with the requirements of the !D!

is communicated and published for interested persons, including people with disabilities and disability

advocacy groups. The MPRB ADA Notice will be included on the agency web site; posted at facilities;

published with guidebooks, job announcements and meeting notices; broadcast as a public service

announcement and periodically printed in the local newspaper. The appendix includes the content of

the public notice or variation thereof.

2. Designation of Responsible Employee Title II requires a public entity to appoint an employee to coordinate and carry out the MPR�’s

compliance efforts, including investigation of complaints.2 To maximize efficiency and ensure ADA

compliance in all facets of the agency, a multi-level approach has been developed with compliance

responsibilities lying with the Deputy Superintendent; coordinating efforts with the ADA Coordinator;

and operational tasks delegated to the Accessibility Management Team.

1 28 CFR §35.106 Notice 2 28 CFR § 35.107(a) Designation of Responsible Employee


mailto:[email protected]

Deputy Superintendent

ADA Designated Responsible Employee

Outreach & Access

Coordinator

ADA Coordinator

Director of Human

Resources

Employment

Director of Asset Management

Co-Leader Transition Plan

Implementation

Director of Design & Project

Management

Co-Leader Transition Plan

Implementation

Therapeutic Recreation &

Inclusion Coordinator

Inclusive Recreation

Services

Accessibility Management Team

Operational Compliance

Chart 1: Organizational chart of delegated ADA compliance responsibilities.

The Deputy Superintendent is the designated responsible employee overseeing the MPRB ADA

compliance efforts. The Deputy Superintendent serves as the official of record and makes all final

decisions on requests for reasonable modifications to policies, practices and procedures; ADA transition

planning priorities; and final responses to ADA-related complaints.

The Community Outreach and Access Coordinator serves as the ADA Coordinator systematizing the

MPRB ADA compliance program through policy, communications, and community engagement. The

ADA Coordinator facilitates policy development and modifications; leads the collective efforts for ADA

compliance across multiple departments; convenes the Accessibility Management Team; tracks ADA

compliance progress; manages the ADA-related complaint process and records; and continuously seeks

input from disability communities.

An Accessibility Management Team has been organized to include representation across all MPRB

departments. The MPRB Accessibility Management Team works to ensure ADA compliance is effectively

and consistently implemented across the agency, communicating accessibility concerns from community

members and following through on ADA implementation strategies. The Accessibility Management

Team meets at least semi-annually, and more frequently as ADA compliance issues arise.

The Director of Human Resources oversees implementation of the ADA regulations specific to the

application process for employees, interviews, new hires, orientation, workplace reasonable

accommodations, reassignments and benefits. The Director of Human Resources ensures interested

individuals can apply either in-person or online for full time employment positions. Further, the Director


of Human Resources administers the process by which employees can requests reasonable

accommodations, including intake, assessment, implementation, evaluation and record-keeping.

The Director of Asset Management and the Director of Design and Project Management jointly

coordinate the implementation of corrective actions and barrier-removal to improve access for visitors

with disabilities at MPRB parks and facilities. Together, they will communicate with the ADA

Coordinator and Accessibility Management Team to prioritize, budget, schedule and track accessibility

improvements in both existing facilities and new capital projects.

The Therapeutic Recreation and Inclusion Coordinator works with staff in all MPRB programs on how

best to support people with disabilities in programs. The Therapeutic Recreation and Inclusion

Coordinator enables MPRB to initiate immediate contact and assessment as people with disabilities

register for MPRB programs. The Therapeutic Recreation and Inclusion Coordinator also coordinates

staff training on inclusion and leads the MPRB in the development of adaptive and therapeutic

recreation programs.

3. Complaint Procedure Title II requires a public entity to adopt and publish complaint procedures providing for prompt and

equitable resolution of ADA-related complaints.3 The purpose of the ADA complaint procedure is to

provide people with disabilities an informal process to contact an entity regarding an access issue so

that the individual and the public entity may work together toward a mutual and timely resolution.

The MPRB ADA Complaint Procedure is established to meet the requirements of the ADA. It may be

used by anyone who wishes to file a non-employment related complaint alleging discrimination on the

basis of disability in the provision of services, activities, programs, or benefits by the MPRB; The MPR�’s

Personnel Policy governs employment-related complaints of disability discrimination.

The complaint should be in writing and contain information about the alleged discrimination such as

name, address, phone number of complainant and location, date, and description of the problem.

Alternative means of filing complaints, such as personal interviews or a tape recording of the complaint,

will be made available for persons with disabilities upon request.

The complaint should be submitted by the grievant and/or his/her designee as soon as possible but no

later than 60 calendar days after the alleged violation to:

Elise Niedermeier, ADA Coordinator

Minneapolis Park and Recreation Board

2117 West River Road

Minneapolis, MN 55411

[email protected]

Within 10 business days after receipt of the complaint, the ADA Coordinator or their designee will meet

with the complainant to discuss the complaint and the possible resolutions. Within 10 business days of

the meeting, the ADA Coordinator or their designee will respond in writing, and where appropriate, in a

format accessible to the complainant, such as large print, Braille, electronic file or audio. The response

3 28 CFR § 35.107(b) Complaint Procedure



will explain the position of MPRB, offer options for substantive resolution of the complaint and

articulate next steps of the review of the complaint.

If the response does not satisfactorily resolve the issue, the complainant and/or their designee may

appeal the decision within 10 business days after receipt of the response to the Deputy Superintendent

or their designee. Within 10 business days after receipt of the appeal, the Deputy Superintendent or

their designee will meet with the complainant to discuss the complaint and possible resolutions.

Within 10 business days after the meeting, the Deputy Superintendent or their designee will respond in

writing, and, where appropriate, in a format accessible to the complainant, with a final resolution of the

complaint. All written complaints received by the ADA Coordinator, appeals and responses will be

retained by the Minneapolis Park and Recreation Board for at least three years.

4. Self-Evaluation: Policies, Practices and Procedures Title II requires a public entity to evaluate its current services, policies, and practices to the extent

modification of any such services, policies, and practices are necessary to enable participation by people

with disabilities.4

Between December 2014 – December 2015, a comprehensive review of agency policies and procedures

was conducted under contract by a consultant and in conjunction with the accessibility assessment of

parks and facilities. The consultant reviewed approximately 42 agency policies and procedures. In

addition, the consultant conducted more than 32 hours of interviews with key personnel across all

MPRB departments. Recommendations were received on 14 policies to modify the language or clarify

the process to better serve people with disabilities in MPRB programs, services and activities. Upon

receipt of the recommendations, staff worked to synthesize a framework for action items that most

immediately impact people with disabilities participating in MPRB programs.

The ADA Action Plan matrix outlines specific agency policies requiring modifications to clarify language

and ensure people with disabilities are fully able to participate and benefit from MPRB programs,

services and activities. Specific policy and procedure changes have been delegated to lead departments

and lead staff with a targeted timeline. Some actionable policies and procedures can easily be modified

within the responsible unit or department. Other actionable policies, such as ordinances, require

proposed modifications be brought to the Park Board of Commissioners for adoption. Therefore, some

modifications may have an extended target timeline.

The ADA Coordinator will manage, monitor, track and publish an annual update to the ADA Action Plan

matrix and make it available to the public upon request.

5. Transition Plan: Existing Facilities Title II requires a public entity to develop a transition plan if structural changes to facilities are necessary

in order to achieve program accessibility.5

4 28 CFR § 35.105 Self-Evaluation 5 28 CFR § 35.150(d) Transition Plan


MPRB began developing its transition plan in late 2014, when a consultant began conducting access

audits at 207 sites throughout the park system’s 6,804 acres. Each site comprises a unique array of

elements that were assessed for their accessibility.

The consultant findings comprise more than 100 electronic files, 19 binders and thousands of images.

Individuals interested in the findings from a specific park or recreation facility can contact Elise

Niedermeier, ADA Coordinator, Minneapolis Park and Recreation Board, 2117 West River Road,

Minneapolis, MN 55411, [email protected].

The consultant identified three types of corrective actions and accessibility improvements applied to

elements (or aspects of elements) that are required to bring the site into compliance with Minnesota

and federal accessibility guidelines.

207 sites audited Sample range of elements assessed

• Parks

• Recreation and community centers

• Ice arenas

• Golf clubs

parking lots, playgrounds, swimming pools/wading pools, docks, picnic shelters, benches, drinking fountains, signage, building entryways and interior doorways, gymnasiums, multi-purpose rooms, kitchens, restrooms and locker rooms

Type* of corrective action

General requirements for each type of action Estimated cost**

1 Corrective actions that can be made as part of routine maintenance (relocating garbage cans or insulating pipes under accessible lavatories); and more complex corrective actions that require planning and design work

$6,546,914

2 Accessibility improvements to playgrounds, golf facilities, sports courts and fields, boating and fishing areas and other recreation elements covered in the 2010 ADA Standards for Accessible Design

$5,745,633

3 Corrective actions or capital improvements that require long-range planning for trails, picnic areas and other outdoor developed areas that are not yet part of the !D!’s final and enforceable design standards

$11,318,950

Total cost of corrective actions: $23,611,497

*Note: the consultant referred to each type of corrective actions as a “phase,” but did not recommend actual

phasing with specific timing, ordering or prioritizing of the actions.

**Estimated cost to implement each type were determined using RS Means Cost Indexing, and include 10%

for staff time, 10% for fixtures and materials, 6% for design and engineering services, and adding a 5% design

and construction contingency.



Funding for accessibility actions and improvements. A key source of funding for these corrective

actions and accessibility improvements comes through the MPR�’s 20-Year Neighborhood Park Plan

(NPP20) Ordinance, approved in 2016. NPP20 includes approximately $800,000 annually, through 2036,

targeted to specific accessibility improvements that are identified in the Access Audit and are not a part

of a larger capital project.

Prioritizing and selecting improvements. Priorities for accessibility improvements will be determined to

achieve the Title II standard for “program access” such that “when viewed in its entirety,” each program,

service or activity is readily accessible to and usable by people with disabilities.

Accessibility priorities will be coordinated with

capital and rehabilitation projects identified in

the MPR�’s six-year Capital Improvement

Program (CIP), which is updated annually and

includes funding allocations through NPP20.

Therefore, ADA corrective actions and

accessibility improvements may be

implemented either through NPP20’s $800,000

dedicated funding, or by way of capital and

other rehabilitation projects that the ADA

would consider to be “alterations” or “new

construction”: That status triggers compliance with the 2010 ADA Standards for Accessible Design along

with the 2015 Minnesota Accessibility Code.

Factors considered in prioritizing accessibility improvements for a program, service or activity

• visitor/participant use

• program/facility goals

• location

• asset condition and lifespan

• duplication of the element(s) to be modified

• degree by which the barrier prohibits participation by people with disabilities

Implementing the ADA Transition Plan. For successful implementation, the MPR�’s !D! Transition Plan

must be sustained as a dynamic, flexible, working document, with joint coordination by the Director of

Asset Management and the Director of Design and Project Management with input from the ADA

Coordinator and Accessibility Management Team. The MPRB ADA Transition Plan will be published on

April 18, 2018 with a one-year schedule of accessibility improvements. Annual updates will report

completed and upcoming accessibility improvements and corrective actions and the status of longer

term projects, as well as adjustments that may have been made based on public input or unforeseen

circumstances such as storm damage or vandalism.

The MPRB ADA Transition Plan, including annual updates, will be posted to the “accessibility” page of

the MPRB web site and announced by the ADA Coordinator to interested parties. The plan and annual

updates will also be made available in alternate formats upon request. As accessibility improvements

are proposed, residents with disabilities and disability advocates will be invited to provide input. Public

input is vital to the planning process and will be welcomed at any time during the year. Questions and

comments should be directed to Elise Niedermeier, ADA Coordinator, at (612) 230-6400 or

[email protected].



Year Tasks Supporting Title II Administrative Requirements

Accountability Timeline

2016 Conduct an ADA self-evaluation of policies, practices and procedures and make identified modifications.

ADA Coordinator; Accessibility Management Team

Assessment completed 2016; Modifications ongoing

2017 Coordinate implementation of MPRB ADA Transition Plan for ongoing barrier removal.

Director, Asset Management; Director, Design & Project Management

Ongoing; 2018 transition plan published Q2 2018

2017 Designate an employee to coordinate ADA Compliance, including investigation of complaints. Make available to all interested individuals the name, office address, and telephone number of the employee or employees.

Deputy Superintendent Completed Q4, 2016

2017 Create and launch accessibility landing page for minneapolisparks.org.

ADA Coordinator Page launched Q3 2017

2017 Outline and publish the procedure for individuals with disabilities to promptly and equitably seek resolution to ADA-related complaints.

ADA Coordinator Completed Q3 2017

2018 Update MPRB ADA Notice to the Public. Develop communication schedule to broadly communicate through agency publications and as a legal notice in the local newspaper. Design a poster that can be used as a public notice on display at MPRB facilities, programs, services and activities.

ADA Coordinator Notice updates Q2 2018 Communication schedule Q2 2018 Poster design & deployment Q4 2018

MODIFICATION OF POLICIES, PRACTICES & PROCEDURES Title II requires a public entity to make reasonable modifications to policies, practices, or procedures

when the modifications are necessary to avoid discrimination on the basis of disability, unless the public

entity can demonstrate that making the modifications would fundamentally alter the nature of the

service, program, or activity.6 As previously noted, a comprehensive review of agency policies and

6 28 CFR § 35.130(b)(7)


procedures was conducted under contract by a consultant and recommendations were received on 14

policies to modify the language or clarify the process to better serve people with disabilities in MPRB

programs, services and activities.

Staff have since worked to develop this ADA Action Plan, outlining the agency approach to ADA

compliance, policy modifications and implementation of an ADA Transition Plan. Additionally, an ADA

Action Plan matrix has been developed to further identify departmental tasks that will contribute to the

successful administration of an ADA compliance program. The Accessibility Management Team has

been organized to guide development and modifications of policies, practices and procedures along with

the specific tasks framed in the ADA Action Plan matrix. The ADA Coordinator will manage, monitor,

track and publish an annual update to the ADA Action Plan matrix and make it available to the public

upon request.

In addition to the modification of existing policies, the Accessibility Management Team lead by the ADA

Coordinator will be charged with proposing new policies such as specific guidance on the use of service

animals and other power-driven mobility devices in parks and recreation facilities. More tasks will

address the provision of effective communication, auxiliary aids and services, technology, inclusive

recreation services and ongoing professional development related to the ADA regulations and the

accessibility standards.

The Minneapolis Park and Recreation Board provides a wide variety of programs, services and activities

to residents and visitors. People with disabilities can request alternate formats, auxiliary aides and

services directly from the MPRB department producing the program, service or activity. Individuals

interested in learning more about inclusion and how to access MPRB programs are encouraged to

contact Sarah Thorsen, Therapeutic Recreation and Inclusion Coordinator at 612-230-6400 or

[email protected].

New issues continue to emerge regarding ADA compliance in the field of parks and recreation. The

Accessibility Management Team, as facilitated by the ADA Coordinator, will meet at least semi-annually,

and more frequently as ADA compliance issues arise.

ORGANIZATIONAL AND DEPARTMENTALPOLICY MODIFCATIONS

Year Tasks Supporting Modification of Policies, Practices and

Procedures


2016 Amend Process and Guidelines for Permitting to ensure events are accessible and applicant agrees reasonable modifications shall be provided at applicant expense.

Director, Customer Service

Completed Q4 2016

2017 Develop bid criteria and technical specifications to ensure the procurement of accessible equipment, products

Director, Asset Management; Director, Design & Project Management

In progress, building standards to be completed Q2 2018; exterior site standard development ongoing



and services on a case by case basis.

2018 Modify Board System Master Planning Policies.

ADA Coordinator; Director, Strategic Planning; Director, Community Outreach

2018

2018 Update Sailboat Buoy Assignment Procedures and Registration to include a section on Access for Boat Owners with Disabilities.


2018

2018 Update Canoe Rack Procedures to include a section on Access for Boat Owners with Disabilities.


2018

2018 Modify (Interim) Athletic Field Policy such that applicant agrees that reasonable modifications shall be provided at applicant expense.

Director, Athletics and Aquatics

Q4, 2018

2018 Consider modification of Healthy Food Policy to address the needs of people with food allergies.

Director, Recreation Centers and Programs

Q2 2018

2018 Modify MPRB Golf Policies so golfers with mobility impairments using single rider golf carts as assistive mobility devices will be allowed to approach greens, fairways and tees.

Director, Golf Q4 2018

2018 Modify MPRB Data Practices Policy to include “Requests for records by a person with a disability may be received in alternative formats such as Braille, digitally, or by voice. The MPRB will, in fulfilling the request, provide it in the format in which it was made, or in another format preferred by the requester;”

Deputy Superintendent 2018

2018 Modify MPRB Policy Statements to address ADA Compliance, accessibility, inclusion and universal design.

Deputy Superintendent Additional review and modification will take place in 2018 as part of agency accreditation through CAPRA, the


Commission for Accreditation of Park and Recreation Agencies.

2017 Modify Rec Center Use Policy & Procedures such that applicant agrees that reasonable modifications shall be provided at applicant expense.

Director, Recreation Centers and Programs

Q4 2018

2018 Include language in special events permits and contracts stating that the permit holder/contracting entity will be responsible for complying with the ADA and ensuring the event is accessible to people with disabilities.


Completed 2017 for 2018 permit season.

2018 Modify Section 5(c)(4) of Policies and Guidelines Governing the Use of the Park System, the book of MPRB Policy Statements and Code of Ordinances to allow for the use of wheelchairs and OPMDs on the same paths and in the same spaces as pedestrians.

Deputy Superintendent; ADA Coordinator; Director, Community Outreach

2018

2018 Modify Policies and Guidelines Governing Use of Park System Section 5(c )(11) and the Code of Ordinances by adopting a section specific to service animals used by people with disabilities.

Deputy Superintendent; ADA Coordinator; Director, Community Outreach

2018

2019 Adopt a policy for Other Power Driven Mobility Devices (OPDMDs).

ADA Coordinator; Deputy Superintendent; Director, Community Outreach

2019

2019 Adopt/revise service animal policy.

ADA Coordinator; Deputy Superintendent; Director, Community Outreach

2019


COMMUNICATIONS AND ADVANCE REQUESTS FOR AUXILARY AIDS, SERVICES AND ALTERNATE FORMATS

Year Tasks Supporting Communication, Alternate

Formats, Auxiliary Aides and Services


2017 Acquire assistive listening system for use at public meetings and other events.


2017 Inventory existing websites, mobile apps and other technologies and ensure all websites, mobile apps and other technologies are accessible to people with disabilities.

Director, Communications & Marketing; Director, Information Technology

Ongoing, minneapolisparks.org audit completed Q4 2016, minneapolisparks.org and intranet compliant by Q4 2018, Inventory completed Q4 2017, 3rd party software inventory completed Q2 2017, technology accessibility considerations ongoing as contracts are updated/renewed

2018 Outline procedure for people with disabilities to request a sign language interpreter or real-time captioning for public meetings and other events.

ADA Coordinator Q2 2018

2018 Inventory existing MPRB videos and develop schedule for captioning or the availability of transcripts.

Director, Communications & Marketing; Deputy Superintendent

Anticipated inventory and captioning schedule completed Q4 2018

2018 Ensure all new videos are produced with open captions.

Director, Communications & Marketing; Board Secretary

Starting Q1 2018, ongoing to align with revised media policy

2018 Ensure all new print publications include a statement “This publication available in alternate format (large print, braille, electronic etc.) upon request;”

Executive Team Started Q1 2017; incorporation into organization style guide Q4 2018; Revised MPRB Media Policy 2018


INCLUSIVE RECREATION SERVICES In 2016 MPRB initiated the appointment of a Therapeutic Recreation and Inclusion Coordinator. The

new position requires qualifications as a Certified Therapeutic Recreation Specialist (CTRS), a nationally

accredited certification with education and practical experience serving the wide array of disabilities. It

should be noted that Therapeutic Recreation is programming specifically structured for people with

disabilities. Inclusion means having programs that are welcoming and accessible to people of all ability

levels – all are welcome, all participate, and all belong. The addition of the Therapeutic Recreation and

Inclusion Coordinator enables MPRB to initiate immediate contact and assessment as individuals with

disabilities register for recreation programs. The Therapeutic Recreation and Inclusion Coordinator is

able to conduct a professional TR assessment of the individual’s needs and put supports, albeit

modifications, equipment or staff, into place to ensure he or she is fully able to participate on day one of

the program.

Year Inclusion Support Tasks


2016 Include statement on website and in all program guides with contact information for making disability-related requests.

Therapeutic Recreation and Inclusion Coordinator

Completed Q3 2016

2016 Set up contractual services with sign language provider.


2017 Update registration process to include section for participants to make initial disability-related requests.


Completed Q4 2017

2017 Outline assessment process for inclusion in staff manual.


Completed Q3 2017

2017 Inventory and develop plan to access/acquire adaptive equipment.


Ongoing

2017 Outline process for evaluating new requests for personal and medical supports.


Completed Q3 2017

2017 Update Recreation Standards and Measurements Manual to include inclusion practices.


Completed Q2 2017


2018 Define supports available through inclusion process and publish agency inclusion manual for staff training and guidance.


Q4 2018

2018 Develop technical assistance manual for staff, volunteers, vendors and partners that includes information on ADA regulations and universal design principles.

ADA Coordinator Q4 2018

EMPLOYMENT & PROFESSIONAL DEVELOPMENT The MPRB is committed to the fair and equal employment of people with disabilities. While many

individuals with disabilities can work without accommodation, other qualified applicants and employees

face barriers to employment without the accommodation process. The MPRB will make every effort to

provide reasonable accommodations to qualified individuals with disabilities unless the accommodation

would impose an undue burden on the organization.

In accordance with the Minnesota Human Rights Act and the Americans with Disabilities Act,

accommodations will be provided to qualified individuals with disabilities when such accommodations

are directly related to performing the essential functions of a job, competing for a job, or to enjoy equal

benefits and privileges of employment. The Director of Human Resources oversees implementation of

the ADA regulations specific to employment.

The policy and procedure for employees to request ADA accommodations was last updated in 2017 and

will continue to be monitored for updating as new regulations and best practices are published. The

ADA Action Plan matrix has identified additional employment priorities to include the development of a

system to track ADA accommodations, and an expanded process to recruit and hire people with

disabilities.

Year Tasks Supporting Recruitment and

Employment of People with Disabilities


2016 Format job descriptions with essential functions, marginal functions and physical requirements for each position.

Director, Human Resources

Started Q4 2016, Ongoing as positions become vacant


2017 Review hiring practices to ensure recruitment sources include organizations that train and place people with disabilities and that job announcements, job fairs etc. are accessible to people with disabilities.


Recruitment sources review completed Q4 2016, job fair accessibility considerations ongoing on an event by event basis

2017 Update procedure for employees to request ADA accommodations.


Completed Q4 2017

2017 Develop system to track ADA accommodations process.


Completed Q1 2017

Through the ADA Action Plan matrix, staff have proposed a multi-faceted approach to support

professional development and build agency knowledge for ADA compliance. The consultant’s review of

policies and procedures found MPRB staff to have many diverse credentials and certifications

representing the fields of park management, recreation services, sport, human resources, finance,

planning, and safety. However, most evident was the lack of on-staff expertise specific to ADA

compliance and therapeutic recreation. Recommendations were made specific to the assignment of

two specific roles, the ADA Coordinator and a Therapeutic Recreation Professional. Title II requires a

designated compliance official and is often referenced as an ADA Coordinator. In early 2016, the ADA

Coordinator was able to enroll in and complete the ADA Coordinator Training Certification Program

offered through the Great Plains ADA Center. This certification program is recognized among peers as

the most in-depth program to support the responsibilities of ADA coordinators in public entities.

In 2017, a series of ADA-compliance training sessions were offered for all staff to establish a

foundational understanding of the key principles of Title II, in addition to sessions focusing on

accessibility standards, maintenance, universal design, program access and customer service. The

information from these sessions will be incorporated into new staff training to ensure a broad base of

agency knowledge.

Year Tasks Supporting Professional Development


2016 ADA Coordinator to complete ADA Coordinator Training Certification Program (ACTCP).


2017 Training for planners, facilities and maintenance

ADA Coordinator Ongoing beginning Q1 2017


personnel on federal and state accessibility standards.

2017 Support continuing education for staff on emerging trends and best practices of universal design applications in park and recreation settings.

ADA Coordinator Ongoing beginning Q1 2017

2018 Develop ADA accommodations training modules for supervisors and managers.


Q4 2018

COMMUNITY ENGAGEMENT & INPUT FROM PEOPLE WITH DISABILITIES Title II requires a public entity to provide an opportunity to interested persons, including individuals with

disabilities or organizations representing individuals with disabilities, to participate in the self-evaluation

process and development of the transition plan by submitting comments.7

Community engagement was conducted from January 2014 through August 2015 to inform

communities about the development of the ADA Transition Plan and Self Evaluation and gather input. In

addition, specific questions were asked on recreational experiences, amenity use and community

preferences for dispersal or concentration of accessible amenities.

A key stakeholder meeting was held January 2014 prior to widespread community engagement as a way

to connect with key community leaders and plan future engagement sessions. With the help of the

Minneapolis Advisory Committee on People with Disabilities (MACOPD), MPRB identified and invited key

community stakeholders to learn more about its ADA Action Plan. Attendees were asked about other

groups and individuals to engage, provided input on the questions MPRB planned to ask during the

engagement process and were invited to partner with the MPRB to co-host engagement events with the

communities they serve.

Groups MPRB reached out to include but are not limited to the ARC Greater Twin Cities, the Epilepsy

Foundation of MN, the MACOPD, Minneapolis Public Schools Early Childhood, the Metropolitan Area

Agency on Aging, Autism MN, the Commission of Deaf, DeafBlind and Hard of Hearing Minnesotans, the

City of Minneapolis Neighborhood and Community Relations Department, the Direct Support

Professional Association of Minnesota (DSPAM), and CanDo Canines.

Community meetings were then held on April 28 and April 30, 2015 at Lake Nokomis Community Center.

These meetings provided community members with an opportunity to learn about the status of MPR�’s

ADA Action Plan and to provide input on their use of the parks and current accessibility concerns. One

was a general community meeting and one focused on parents of children with disabilities.

7 28 CFR § 35.105(b) Self-Evaluation and § 35.150(d)(1) Transition Plan


While there was significant interest among the key stakeholder group in co-hosting engagement

meetings, ultimately organizations did not have the capacity to support this level of engagement.

However, they were instrumental in sharing opportunities for community members to provide feedback

through surveys and MPRB open houses.

Between April 28, 2015 and August 31, 2015 more than 60 community members completed a survey

regarding preferences and priorities related to the ADA Action Plan. The survey was available online and

paper copies were made available in all rec centers and at a series of engagement meetings for the

Closing the Gap initiative. The survey was promoted through email via the key stakeholder group and

was linked to the project page on the MPRB website.

Staff from the ADA workgroup were in attendance at the �ity of Minneapolis’ 25th !nniversary !D!

Celebration to provide information about the status of the project and get feedback to inform the plan.

Additionally, contact was initiated with the following community groups: Advocating Change Together

(!�T), Governor’s �ouncil on Disability, U of M Institute on �ommunity Integration, P!�ER �enter,

Metropolitan Center for Independent Living, Courage Center, Dowling School, Adapt Minnesota, and

Southside Services.

Input from individuals with disabilities and disability advocacy groups is essential to the successful

implementation of the MPRB ADA Action Plan and forthcoming ADA Transition Plan. The ADA

Coordinator provides regular updates to the MACOPD, which in turn provides valuable input on the

preferences and best practices to serve people with disabilities. MPRB will continue to consult with the

MACOPD for program and policy development as well as transition plan implementation. Through the

community engagement process, the ADA Coordinator has also been able to develop new relationships

with disability-service organizations that should be able to provide constructive feedback for future

growth.

Most important, and reflective of the MPRB’s commitment to inclusion, people with disabilities and

disability advocates are encouraged to provide public comment during the formal period related to the

release of this draft ADA Action Plan and at any point in the future. Our staff welcome feedback and the

opportunity to transform accessibility challenges into new opportunities to build a more inclusive

community.

Year Tasks Supporting Input from People with

Disabilities


2016 Continue to seek input from residents and visitors with disabilities.

ADA Coordinator, all staff

Ongoing

2016 Continue to seek input from MACOPD on direction of transition plan, policy development.

ADA Coordinator Ongoing

2017 Ensure people with disabilities are

Director, Community Outreach

Ongoing


represented on advisory boards and committees.

2018 Convene MPRB advisory committee of people with disabilities to provide input on inclusive programming.

Therapeutic Recreation and Inclusion Coordinator; ADA Coordinator

Q4 2018

RESOURCES Any Minneapolis residents or MPRB program participants with questions about the implementation of

the MPRB ADA Action Plan are encouraged to call or e-mail the ADA Coordinator:

Elise Niedermeier, ADA Coordinator Minneapolis Park and Recreation Board 2117 West River Road Minneapolis, MN 55411 (612) 230-6400

[email protected]

For general questions about the Americans with Disabilities Act, contact:

U.S. Department of Justice

(800) 514-0301

www.ada.gov

U.S. Access Board

(800) 872-2253

www.access-board.gov

Great Lakes ADA Center

(800) 949-4232

www.adagreatlakes.org



http://www.ada.gov/

http://www.access-board.gov/

http://www.adagreatlakes.org/

Appendix A MPRB ADA Public Notice

MPRB Notice Under the Americans with Disabilities Act

Recreation is for everyone! The Minneapolis Park and Recreation Board (MPRB) is committed to the spirit and intent of the Americans with Disabilities Act. In accordance with the requirements of title II of the Americans with Disabilities Act of 1990 ("ADA"), the MPRB will not discriminate against qualified individuals with disabilities on the basis of disability in its services, programs, or activities.

Employment: People with disabilities are encouraged to apply for seasonal employment, full-time and volunteer opportunities. The MPRB does not discriminate on the basis of disability in its hiring or employment practices and complies with all regulations promulgated by the U.S. Equal Employment Opportunity Commission under title I of the ADA.

Effective Communication: The MPRB will generally, upon request, provide appropriate aids and services leading to effective communication for qualified persons with disabilities so they can participate equally in MPRB programs, services, and activities, including qualified sign language interpreters, documents in Braille, and other ways of making information and communications accessible to people who have speech, hearing, or vision impairments.

Modifications to Policies and Procedures: The MPRB will make all reasonable modifications to policies and programs to ensure that people with disabilities have an equal opportunity to enjoy all of its programs, services, and activities. For example, individuals with service animals are welcomed in all MPRB facilities, even where pets are generally prohibited.

Anyone who requires an auxiliary aid or service for effective communication, or a reasonable modification of policies or procedures to participate in a program, service, or activity of the MPRB, should contact Elise Niedermeier, ADA Coordinator, at (612) 230-6400 or [email protected] as soon as possible but no later than 72 hours before the scheduled event.

The MPRB will not place a surcharge on a particular individual with a disability or any group of individuals with disabilities to cover the cost of providing auxiliary aids/services or reasonable modifications of policy, such as retrieving items from locations that are open to the public but are not accessible to persons who use wheelchairs.

The ADA does not require the MPRB to take any action that would fundamentally alter the nature of its programs or services, or impose an undue financial or administrative burden.

Complaints: Comments, concerns and/or complaints that a program, service, or activity of the MPRB is not accessible to persons with disabilities should be directed to Elise Niedermeier, ADA Coordinator, at (612) 230-6400 or [email protected].




Documents

Draft ADA Action Plan - Home - Minneapolis Park ...€¦ · The updated accessibility standards and 25th anniversary of the ADA in 2015 have also presented MPRB with an opportunity